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The letter stresses the importance of only authorised persons carrying out or signing off on financial advertisements, as well as the need to present a balanced view of the service offered, with the risks associated clearly communicated to consumers. For BNPL, this can include the risk of accumulating unpayable debt, as well as the consequences of non-repayment.
This will be particularly vital for merchants operating an own-label BNPL or finance solution, as well as any third-party BNPL providers, especially if additional friction at the checkout affects the customer experience relative to other payment methods.
While many retailers advertising third-party BNPL providers as a means of payment may be exempt from regulations in several cases,² it’s crucial that all merchants understand how to effectively implement these regulations and the FCA’s position in detail - or risk the consequences.